I have a formal response with recommendations to NESP 2026

Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 1

Clean Energy Solutions

Clean Energy Strategy

NATIONAL ELECTRICITY SECTOR POLICY 2026

Formal Consultation Response & Policy Development Proposal

Submitted by

W. Dwayne Trott, Founder & CEO

Organisation

A1sension Sustainable Building Co. Ltd (trading as Clean Energy

Solutions)

Clean Energy

Clean Energy Strategy — Clean Energy Solutions

Date

April 2026

Reference

NESP 2026 Consultation Draft — April 7, 2026

Regulatory relationship

BMA Innovation Hub participant | RA Large-Scale Self-Supply pathway

confirmed

This document constitutes a formal consultation response to the National Electricity Sector

Policy 2026 Consultation Draft. It is submitted by Clean Energy Solutions, the institutional

delivery vehicle behind the Clean Energy Strategy— a multi-vertical sovereign infrastructure

initiative spanning Power, Fresh, Living, Academy, and Digital verticals across Bermuda.Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 2

Executive Summary

The Clean Energy Strategy, delivered by Clean Energy Storage Solutions (trading as Clean

Energy Solutions), submits this formal response to the NESP 2026 Consultation Draft with three

objectives.

First, to validate that the Clean Energy's Power vertical architecture — islanded molten

carbonate fuel cell (MCFC) generation supported by layered battery energy storage, fuelled by

LNG/CNG transitioning to RNG and hydrogen — represents exemplary implementation of the

NESP 2026's core policy principles of affordability, reliability, resilience, and technology-

agnostic evaluation.

Second, to demonstrate that the Large-Scale Self-Supply (LSSS) licence pathway, as confirmed

in writing by the Regulatory Authority of Bermuda in April 2026, provides the correct and

unobstructed regulatory framework for this architecture — and that this pathway should be

formally recognised and expanded within the NESP framework as a distinct and strategically

important licence category.

Third, to propose specific policy developments— including a framework for licensed energy

services delivery within islanded LSSS installations— that would unlock significant private

capital investment in Bermuda's energy transition without placing any burden on BELCO's

ratepayer base.

Clean Energy Architecture at a Glance

Generation: FuelCell Energy DFC3000 Molten Carbonate Fuel Cell (MCFC) — firm dispatchable

baseload

Short-term storage: Sumitomo Electric VRFB — daily cycling, four-hour duration

Long-term storage: Form Energy iron-air BESS — multi-day resilience, Phase 2

Fuel pathway: LNG/CNG (Phase 1) → Biogas/RNG (Phase 2) → Green Hydrogen (Phase 3)

Configuration: Fully islanded sovereign microgrid — no BELCO grid interconnection

Licence pathway: Large-Scale Self-Supply, confirmed technology and fuel-type agnostic by RA

Primary sites: Southside St David's, Pembroke, Deveonshire Projects

Clean Energy financing milestone: Financial deliverables — 21 July 2026Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 3

1. Clean Energy Overview

The Clean Energy Strategy is a multi-vertical sovereign infrastructure initiative structured around

five integrated delivery pillars: Power (MWIEC/EBSC/CESS-BDA), Fresh (Compass Point and

Southside Campus), Living (Westcott Road), Academy, and Digital.

The combined high-case capex of the Clean Energy Solutions project development is

approximately $1,011.1M, with UKEF export finance eligibility of $31.1M. The Clean Energy

Strategy is designed to be entirely privately funded, imposing no capital burden on the

Government or on BELCO's ratepayer base.

The Power vertical— the subject of this consultation response— is structured around an

inventory of fully islanded sovereign microgrid projects delivering firm baseload generation,

layered storage, and integrated thermal energy services to co-located Fresh, Digital, and Living

infrastructure.

1.1 Why the NESP 2026 Matters to the Clean Energy Strategy

The NESP 2026 is the policy framework within which the LSSS licence application will be

evaluated and within which the Clean Energy's technology and fuel choices will be assessed by

the RA, Government stakeholders, and institutional financing counterparties. A clear record of

alignment between the Clean Energy architecture and the NESP's stated policy objectives is

therefore a material input to the financial deliverables process and to Clean Energy's investor

engagement.Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 4

2. NESP 2026 Alignment Analysis

This section maps each core NESP 2026 policy objective to the Clean Energy Solutions Power

vertical architecture, demonstrating direct and substantive alignment across affordability,

reliability, resilience, technology neutrality, and the IRP/LSSS structural framework.

2.1 Technology-Agnostic Policy Framework

The NESP 2026 explicitly adopts a technology-agnostic approach, stating that it does not

prescribe specific generation technologies and that investments will be evaluated on their

contribution to affordability, reliability, emissions reduction, and system resilience. This is the

single most important policy provision for the Clean Energy.

MCFC technology has not previously appeared in Bermuda's IRP and therefore cannot enter

the market through the bulk generation or BTM distributed generation pathways. The NESP's

technology-agnostic stance, combined with the confirmed LSSS pathway, removes this

constraint entirely. The Clean Energy Strategy operates in the correct regulatory category for

exactly the reason the NESP identifies: the LSSS licence was created to accommodate

technologies and configurations that the IRP has not yet evaluated.

RA Confirmation — April 2026

"Applications for a Large-Scale Self-Supply licence are not limited to specific technologies or fuel

types."

"The approved fuel source(s) would be reflected within the licence itself for the purposes of electricity

generation."

Source: Written correspondence from the Regulatory Authority of Bermuda, April 2026

2.2 Affordability and Tariff Stabilisation

The NESP 2026 establishes tariff stabilisation as the primary policy objective, with the 2025

average retail tariff as the reference baseline. Bermuda's current generation mix is 84% fossil

fuel, predominantly heavy fuel oil— among the highest-cost and highest-emission generation

fuels available. The Clean Energy's MCFC architecture addresses this directly.

Dimension

Current BELCO Position

MCFC/BESS Architecture

Primary fuel

Heavy fuel oil (HFO)

LNG/CNG → RNG → Green

Hydrogen

Efficiency

~35% thermal efficiency

~47% electrical + CHP thermal

recovery

Fuel price exposure

High — global HFO markets

Significantly reduced; transition toClean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 5

biogas/H2

Tariff pressure

Fixed cost recovery on declining

sales base

Self-supply: zero tariff burden on

BELCO base

Emissions intensity

High — HFO combustion

Materially lower; pathway to zero-

carbon

Critically, because each project development operates as a fully islanded self-supply installation,

it removes demand from BELCO's grid entirely. This is a net benefit to remaining ratepayers—

fewer large consumers drawing fixed-cost recovery from a declining sales base— which is

precisely the dynamic the NESP identifies as Bermuda's primary tariff pressure driver.

2.3 Resilience and Multi-Day Storage

Section 5.3 of the NESP states explicitly that the IRP must ensure adequate firm generation

capacity under extended adverse conditions, including multi-day weather events during which

variable renewables and battery storage may be unavailable. No technology currently proposed

in Bermuda's energy landscape addresses this requirement.

The Clean Energy Solutions Power vertical addresses it directly through a three-layer storage

architecture:

Storage Layer

Role and Capability

MCFC Baseload

Continuous firm generation— 24/7 dispatchable, weather

independent, no intermittency

Sumitomo VRFB

Daily cycling— absorbs daytime solar DG excess, dispatches

evening peak; four-hour duration

Form Energy Iron-Air

Multi-day resilience— designed specifically for 100+ hour

discharge; addresses hurricane/storm scenario

This layered architecture— firm generation plus short-duration plus long-duration storage— is

the configuration the NESP describes as necessary for Bermuda's isolated grid but which no

existing or proposed solution delivers. The Clean Energy Strategy is therefore not merely

compliant with the NESP's resilience objectives; it is the most substantive response to them in

the current market.

2.4 Fuel Transition Pathway

The NESP acknowledges that fossil fuels will remain part of Bermuda's energy mix for the

foreseeable future while supporting a progressive transition toward lower-carbon intensity. The

Clean Energy's fuel roadmap is structured in direct alignment with this policy trajectory:Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 6

Phase

Fuel Type

NESP Alignment

Phase 1 (Immediate)

LNG / CNG

Lower-carbon than HFO; LSSS

licence

confirmed,

fuel-type

agnostic

Phase 2 (Medium-term)

Biogas / Renewable Natural Gas

(RNG)

Renewable fuel input; closed-loop

CO₂ utilisation with IGS farm

Phase 3 (Long-term)

Green Hydrogen

NESP Section 7.3 acknowledges

hydrogen potential; zero-carbon

endpoint

The CO₂ closed loop is particularly significant. MCFC operation produces CO₂ as a

byproduct. One of the projects being developed integrates vertical farming and a food lab that

consume CO₂ as a growth input. This creates a closed-loop integration that is only possible

with co-located energy, computing, farming, and food infrastructure— a systems architecture

that no conventional generation technology can replicate.Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 7

3. The LSSS Pathway — Regulatory Architecture and Clean

Energy Implications

3.1 The LSSS as Bermuda's Technology Innovation Gateway

The NESP 2026 and the current IRP framework create an important structural dynamic: any

generation technology not yet assessed within the IRP can only enter Bermuda's market

through the LSSS pathway. This means the LSSS is currently the sole regulatory route for

energy technology innovation in Bermuda's generation sector.

This has a significant first-mover implication. The Clean Energy Strategy, by establishing the

first operational MCFC installation in Bermuda under an LSSS licence, will create the reference

proof of concept for any future IRP consideration of fuel cell technology. The Clean Energy

Strategy does not merely benefit from the LSSS pathway— it defines what that pathway looks

like in practice for the most advanced generation architecture currently proposed in the

jurisdiction.

3.2 Scalability Across Commercial, Industrial and Residential Sectors

The LSSS islanded configuration is not inherently limited to large sovereign campuses. The

regulatory requirement is simply that the system operates as a fully islanded installation— no

grid connection, complete self-sufficiency. This configuration is technically achievable across a

range of deployment contexts:

Sector

Application and Rationale

Large Commercial

Hotels, office campuses, marine facilities— high predictable

baseload; significant BELCO tariff exposure removed

Industrial

Cold storage, desalination, manufacturing— MCFC efficiency

advantages maximised at continuous high-load profiles

Mixed-Use Development

Planned developments designed as islanded campuses from the

outset — energy infrastructure as sovereign from day one

Residential Campus

Multi-unit developments where the development entity is the single

LSSS licence holder— Westcott Road model

Each of these deployment contexts is served by the existing LSSS framework without legislative

amendment. The constraint that does require policy resolution— the electricity resale

prohibition— is addressed in Section 4 below.

3.3 The BGSUI Pathway — Secondary Consideration

The NESP 2026 also introduces the BG Sole Use Installation (BGSUI) licence for large-scale

renewable installations above 500kW for self-use, with up to 30% grid export permitted with RAClean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 8

approval. While the LSSS remains the primary and confirmed pathway for the clean MCFC

technology, given its fully islanded configuration, the BGSUI's export provision may become

relevant in future phases where excess generation capacity warrants consideration of grid

contribution arrangements. The Clean Energy Strategy notes this as a potential long-term

flexibility option.

4. Policy Development Proposals

The Clean Energy Solutions Strategy submits the following specific policy development

proposals for consideration by the Ministry of Home Affairs in the finalisation of NESP 2026.

Each proposal is grounded in Clean Energy's Solution’s operational experience with the LSSS

pathway and is designed to unlock private capital investment in Bermuda's energy transition

without burden on the public sector or BELCO's ratepayer base.

4.1 Proposal One: Formal Recognition of LSSS as a Strategic Licence

Category

The LSSS pathway is currently described in Section 4 of the NESP as a residual category—

available where other pathways are not applicable. We propose that the NESP formally

recognize the LSSS as a strategically important licence category in its own right, with a

dedicated policy framework that includes:

• Clear eligibility criteria and technology neutrality confirmation embedded in NESP text

• A streamlined application process with defined timelines and milestones

• Explicit recognition that LSSS installations benefit Bermuda's energy system by

removing demand burden from BELCO's tariff base

• A pathway for LSSS installations to contribute operational data to future IRP processes,

accelerating evidence-based technology assessment

This proposal requires no legislative amendment— it is a policy framing and administrative

process matter that the Ministry can implement through the NESP and associated RA guidance

documents.

4.2 Proposal Two: Licensed Energy Services Delivery Framework for

Islanded LSSS Installations

The current Electricity Act 2016 prohibits electricity resale except by BELCO as the licensed

TD&R entity. This prohibition, while appropriate for grid-connected distribution, creates an

unnecessary constraint on the commercial viability of islanded LSSS installations when they

serve multiple occupants within a defined campus boundary.

We propose the introduction of a Licensed Energy Services Delivery (LESD) framework for

islanded LSSS installations, structured as follows:Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 9

Framework Element

Proposed Position

Scope

Applies exclusively to fully islanded LSSS installations with no grid

interconnection

Permitted activity

LSSS licence holder may deliver integrated energy services to

occupants within the licensed campus boundary

Service Structure

Energy services delivered as a facilities management amenity—

not as metered electricity supply. For Eg. Life Style subscription

for energy, hot water, cooling bundled services.

Consumer Protection

RA oversight of service agreement terms; occupant rights protected

under the Consumer Affairs framework.

Ratepayer Impact

Zero— islanded system imposes no cost on BELCO's grid or

ratepayer base.

Legislative Requirement

Amendment to EA 2016 Section on electricity resale; or Ministerial

direction under existing innovation provisions.

This framework is distinct from any challenge to BELCO's retail monopoly. It applies only within

the physical boundary of an islanded private energy system where no grid infrastructure is

involved. The legal and commercial precedent exists in multiple comparable jurisdictions,

including district energy operators, serviced campus developments, and integrated

infrastructure platforms.

4.3 Proposal Three: LSSS Pilot Clean Energy Recognition

Clean Energy Solutions’ installations at its current project development sites are proposed as

the formal pilot implementation of the LESD framework described in Proposal Two, under the

oversight of the RA and the Department of Energy. This would provide:

• An evidence base for policy refinement before broader legislative amendment;

• Operational data on MCFC performance, fuel transition progression, and storage

integration under Bermuda's climate conditions.

• A replicable model for commercial, industrial, and residential LSSS deployments across

the island;

• A demonstration project that validates Bermuda's energy innovation regulatory

environment to international investors and technology partners.

The Innovative Licence pathway (Section 4.6 of the NESP) provides a suitable interim

framework for the pilot period, with transition to a full LSSS licence upon completion of the pilot

phase.Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 10

4.4 Proposal Four: IRP Inclusion Pathway for LSSS-Proven Technologies

We propose that the NESP 2026 include an explicit pathway by which technologies

demonstrated under the LSSS framework can be formally assessed for inclusion in future IRP

processes. This iterative policy-planning loop— which the NESP already describes conceptually

in Section 5.2 — would create a structured mechanism for LSSS operational data to inform the

next IRP cycle.

For MCFC technology specifically, this means that the Clean Energy Strategy's operational

performance data— generation efficiency, fuel consumption, emissions profile, storage

integration outcomes, and cost-per-kWh— would constitute the investment-grade evidence

base for a future IRP scenario that includes fuel cell generation as a bulk generation option.

This benefits the entire Bermuda energy system, not merely the Clean Energy.Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 11

5. MCFC vs. Current and Proposed Generation Technologies

This section provides a direct comparative analysis of MCFC technology against Bermuda's

current generation mix and the technologies proposed in the NESP 2026 and IRP framework,

evaluated against the NESP's own policy criteria.

Criterion

BELCO HFO

(Current)

Solar PV (IRP

Priority)

Offshore Wind

(IRP

Proposed)

MCFC + BESS

(Clean Energy)

Form

Energy

Iron-Air

Firm/Dispatchable

Yes

No

Partial

Yes — 24/7

Discharge

only

Weather-independent

Yes

No

No

Yes

Yes

Multi-day resilience

Limited

No

No

Yes (with iron-

air)

Yes

—

100hr+

Emission intensity

High (HFO)

Zero

operational

Zero

operational

Low → Zero (H2) Zero

Fuel transition path

None

N/A

N/A

LNG→RNG→H2

N/A

CHP / thermal output

No

No

No

Yes — 650°C

No

Land constraint

Existing plant

High

(80MW

floating)

High (offshore)

Low (modular)

Low

(modular)

IRP pathway

Current BG

IRP priority

IRP proposed

LSSS

(confirmed)

LSSS

(BESS

component)

Ratepayer burden

Yes

Yes (PPA)

Yes (PPA)

Zero

(self-

supply)

Zero

(self-

supply)

The comparative analysis demonstrates that the MCFC plus layered BESS architecture is the

only proposed generation configuration in Bermuda that simultaneously delivers firm

dispatchable baseload, weather independence, multi-day resilience, a credible zero-carbon fuel

transition pathway, thermal energy recovery, and zero burden on BELCO's ratepayer base.

Against the NESP's own evaluation criteria, no currently proposed alternative matches this

profile.Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 12

6. Regulatory and Government Engagement Context

Clean Energy Solution’s has maintained an active and constructive regulatory engagement

throughout the Clean Energy Strategy development process. Key milestones relevant to this

consultation are:

Milestone

Detail

BMA Innovation Hub

Clean Energy invited to participate— established a supportive

regulatory relationship with Craig Swan and Moad Fahmi

BLMC–CESS MOU

Executed 21 January 2026 — confirming 5.88-acre Southside St

David’s site; 21 July 2026 financial deliverables deadline

RA

LSSS

Pathway

Confirmation

Written confirmation received April 2026 — technology and fuel

type agnostic; approved fuels reflected in the licence

RA Consultation Engagement

This submission constitutes formal participation in the NESP 2026

consultation process

UKEF Eligibility

Wescott Project financial model identifies £31.1M UKEF export

finance eligibility

Clean Energy Solutions is uniquely positioned to contribute to the NESP 2026 consultation not

merely as a respondent but as an active implementation partner. The combination of a

confirmed regulatory pathway, established government relationships, a committed site, and

investor-grade financial modelling means that the policy developments proposed in Section 4

can be tested against a live, investment-ready Clean Energy Development Project rather than

remaining theoretical.Clean Energy Solutions | Clean Energy Strategy

NESP 2026 Consultation Response

CONFIDENTIAL | April 2026

Page 13

7. Summary of Positions and Proposals

Positions — Clean Energy Validation

1. The Clean Energy Solutions Power strategy vertical is fully aligned with NESP 2026 core policy

objectives of affordability, reliability, resilience, and technology-agnostic evaluation.

2. The LSSS licence, confirmed in writing by the RA as technology and fuel-type agnostic, is the

correct and unobstructed regulatory pathway for MWIEC.

3. The MCFC plus layered BESS architecture addresses the firm multi-day resilience gap that the

NESP identifies, but that no current or proposed Bermuda generation solution resolves.

4. The fuel transition roadmap (LNG/CNG → RNG/biogas → hydrogen) is directly aligned with the

NESP's progressive decarbonisation framework.

5. The islanded self-supply configuration removes demand burden from BELCO's tariff base — a net

benefit to remaining ratepayers under the NESP's affordability framework.

Proposals — Policy Development

Proposal 1: Formal recognition of LSSS as a strategic licence category with a dedicated policy

framework and streamlined process.

Proposal 2: Licensed Energy Services Delivery (LESD) framework enabling LSSS licence holders to

deliver integrated energy services to campus occupants without constituting electricity resale.

Proposal 3: The designation of multiple Clean Energy Solution projects currently being developed as

formal LSSS pilot implementations under RA and Department of Energy oversight.

Proposal 4: An explicit IRP inclusion pathway for technologies demonstrated under the LSSS

framework, enabling operational data to inform future IRP cycles.

Clean Energy Solutions is available to meet with the Ministry of Home Affairs, the Department of

Energy, and the Regulatory Authority to discuss the substance of this submission at the earliest

convenience. We welcome the opportunity to present the Clean Energy architecture and the

proposed policy developments in detail and to contribute constructively to the finalisation of the

NESP 2026.

Contact: W. Dwayne Trott | Founder & CEO | Clean Energy Solutions Ltd.

This document is submitted in confidence as a formal consultation response. It does not

constitute a public disclosure of commercially sensitive Clean Energy Solution’s information.